News Kadrey v Meta Fourth Amended Complaint April 2026

April 6, 2026 — Judge Allows Fourth Amended Complaint in Kadrey v. Meta, Adding Contributory Infringement Claim Over Torrenting

Judge Vince Chhabria of the U.S. District Court for the Northern District of California reluctantly granted plaintiffs' motion to file a fourth amended complaint in Kadrey et al. v. Meta Platforms, Inc. (Case No. 3:23-cv-03417), adding a contributory copyright infringement claim related to Meta's alleged torrenting of copyrighted books from shadow libraries.<ref name="chhabria-order">Judge Chhabria Grants Kadrey's Request to File 4th Amended Complaint, ChatGPT Is Eating the World, March 25, 2026</ref>

The new claim targets Meta's alleged distribution of copyrighted works through torrenting—a practice distinct from the direct infringement claims for training AI models on pirated books that were already resolved on fair use grounds in the court's June 2025 partial summary judgment ruling. Plaintiffs allege Meta knowingly induced or materially contributed to third-party infringement by downloading and uploading their copyrighted books via BitTorrent from shadow libraries including Library Genesis and Z-Library.<ref name="chhabria-order" /><ref name="mckool">McKool Smith AI Litigation Tracker</ref>

Despite granting the motion, Judge Chhabria strongly rebuked plaintiffs' counsel at Boies Schiller, describing a "pattern" of blaming Meta for case delays and noting that plaintiffs could have added these claims as early as November 2024. The court described the delay as "inexcusable" but ultimately prioritized the interests of absent class members, finding no prejudice to Meta given the ongoing related litigation and shared discovery schedules with the Entrepreneur Media v. Meta case.<ref name="chhabria-order" />

The court also denied class discovery until named plaintiffs survive summary judgment on both the existing distribution claims and the new contributory infringement claims, a significant limitation on the plaintiffs' ability to pursue class-wide relief.<ref name="chhabria-order" />

Background

The Kadrey v. Meta case was filed in July 2023 by authors including Richard Kadrey, Sarah Silverman, and Christopher Golden, alleging Meta used pirated books to train its LLaMA AI models. In June 2025, Judge Chhabria granted Meta's motion for partial summary judgment on fair use grounds for the direct infringement (training) claims, but distribution claims remained unresolved.<ref name="justia">Justia: Kadrey v. Meta Platforms Case Docket</ref>

Significance

This ruling marks an important shift in the case's trajectory, expanding the litigation beyond the direct training infringement claims (already decided on fair use) to include contributory infringement based on distribution activities. The contributory infringement theory could have broader implications for AI companies' liability when their training data acquisition practices involve distributing copyrighted works through peer-to-peer networks.

See Also

• Kadrey v Meta Platforms Inc — Full case page
• Carreyrou v Anthropic PBC — Related opt-out copyright litigation against multiple AI companies
• Cases — Active AI litigation tracker

References

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